+49 6196 5835357

info@ecopv-eu.com

🇵🇱 EPR Compliance for Packaging in Poland |
Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Packaging – 7 Steps to Compliance + Step-by-Step Checklist

Anyone selling packaged products in Poland has a responsibility: Extended Producer Responsibility (EPR) makes companies jointly responsible for the end-of-life of their packaging. In 2026, Poland will be in the midst of a comprehensive reform process: The deposit system (System Kaucyjny) has been in operation since October 1, 2025, and the EU Packaging Regulation (PPWR, Regulation (EU) 2025/40) will apply directly in all EU member states as of August 12, 2026.

What does this mean specifically for your company?

Here are the 8 most important steps – including a checklist to get you started.

🇵🇱 EPR Compliance for Packaging in Poland |
Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Packaging – 7 Steps to Compliance + Step-by-Step Checklist

Anyone selling packaged products in Poland has a responsibility: Extended Producer Responsibility (EPR) makes companies jointly responsible for the end-of-life of their packaging. In 2026, Poland will be in the midst of a comprehensive reform process: The deposit system (System Kaucyjny) has been in operation since October 1, 2025, and the EU Packaging Regulation (PPWR, Regulation (EU) 2025/40) will apply directly in all EU member states as of August 12, 2026.

What does this mean specifically for your company?

Here are the 8 most important steps – including a checklist to get you started.

Who is considered a “manufacturer” under Poland’s packaging EPR regulations?

The EPR obligation applies to any company that places packaged products on the Polish market for the first time on a commercial basis – regardless of where the company is headquartered. Specifically, this applies to:

  • Fillers/packagers based in Poland – those who package or fill goods in Poland and sell them under their own brand name
  • Private-label owners – retailers who have products packaged by third parties and place them on the market in Poland under their own brand
  • Importers – those who commercially import packaged goods into Poland from abroad (EU or third countries)
  • Non-Polish EU companies engaged in distance selling – those who deliver packaged goods directly to Polish end customers via e-commerce (B2C) bear full EPR responsibility for product and shipping packaging – starting with the first shipment
  • Non-EU companies – for direct B2C shipments, the obligation lies with the foreign retailer; in traditional B2B supply chains, the Polish importer is legally considered the manufacturer
  • Marketplace operators – platforms such as Allegro and Amazon.pl bear subsidiary liability; they automatically validate BDO numbers and suspend accounts in cases of non-compliance with packaging regulations

Important – no quantity threshold: The BDO registration requirement applies in Poland starting with the first package placed on the Polish market. There is no exemption from the registration requirement for small quantities.

Practical example: An Austrian online store ships packaged cosmetic products directly to Polish consumers → is considered a manufacturer under the packaging EPR → must apply for a Polish NIP tax number → appoint an authorized representative in Poland → complete BDO registration with the Marshal’s Office in Warsaw (Masovia) → enter into a take-back system agreement → include the 9-digit BDO number on invoices → enter the BDO number in the Amazon.pl and Allegro backends

The 7 Most Important Steps for Packaging Compliance in Poland

Step 1: Appoint an Authorized Representative (for Foreign Companies)

Foreign online retailers not based in Poland that sell packaged goods directly to Polish consumers (B2C) must appoint an authorized representative based in Poland.

The authorized representative assumes joint and several financial and administrative responsibility for registration in the take-back system and for the annual report submitted via the BDO portal.

Requirements for the power of attorney documentation:

  • Written power of attorney in Polish (or bilingual Polish/English)
  • Proof of the foreign signatory’s authority to act on behalf of the company (e.g., an extract from the commercial register) must be attached
  • A Hague Apostille is not required as a standard for BDO registration
  • The foreign company must have a Polish NIP tax number so that the authorized representative can successfully complete the BDO registration process. The NIP must be applied for separately at the relevant tax office in Warsaw.

Step 2: Mandatory Registration in the BDO Registry

The BDO is Poland’s central, cross-product environmental and EPR registry – it combines packaging, WEEE, batteries, and other categories into a single system.

Registration platform: bdo.mos.gov.pl

Process:

  1. Fully digital application in Polish
  2. Required information: NIP, packaging materials (plastic, paper, glass, etc.), proof of a take-back system contract
  3. Upon approval by the Marshal, a unique 9-digit BDO number is assigned

BDO annual fee: Due by the end of February of each year

The BDO fee is a flat rate that applies to all registered categories – those who register packaging, WEEE, and batteries pay the same flat rate.

Step 3: Membership in a Take-Back System

Membership in a government-approved take-back system is mandatory. In Poland, there are several approved systems competing with one another.

Individual Self-Management:

  • Practically irrelevant for household packaging (B2C): The manufacturer would have to provide mathematical proof that it recovers exactly its own packaging waste from all Polish households.
  • Permitted in the pure B2B sector (e.g., transport pallets between industrial companies) through direct, documented contracts with commercial customers

Step 4: Collect packaging data and report annually

Content of the report: Exact weight figures (in kg) for all packaging placed on the market in Poland in the previous year, broken down by material type and intended use (B2C vs. B2B).

Deadlines:

  • Annual report: By March 15 of each year, submitted electronically via the BDO portal
  • Intra-year reports: Take-back systems require monthly or quarterly declarations in the system’s backend for billing purposes

Step 5: Calculate and Pay Fees

License fee to the take-back system: Calculated per metric ton/kilogram of packaging material placed on the market, strictly separated by material group.

Eco-modulation:

  • Benefits: Unpigmented monomaterials (e.g., clear PP or PE without barrier layers) and recyclable packaging receive fee discounts
  • Penalty surcharges: Multilayer plastics without a recycling pathway are subject to surcharges

Step 6: Deposit System – Active Since October 1, 2025

The Polish national deposit system has been in operation since October 1, 2025.

Covered packaging and deposit amounts:

Packaging typeDeposit amount
Single-use PET bottles up to 3 liters0,50 PLN
Metal cans up to 1 liter0,50 PLN
Reusable glass bottles up to 1.5 liters1,00 PLN

Exceptions: Packaging for dairy products and small bottles below certain volumes are exempt.

Obligations for beverage manufacturers and importers:

  • Register packaging subject to the deposit with the relevant system operator
  • Affix the “Kaucja” logo and the deposit amount to the packaging (with a barcode)
  • Pay system fees to the operator

Step 7: Labeling, BDO Number on Documents & Product Delivery

1. Material Labeling:

  • Requirement to label materials with the Europe-wide harmonized identification codes

2. BDO Number on Business Documents:

  • The 9-digit BDO number must appear on all invoices, delivery notes, and commercial documents issued by the distributor

3. Product Levy:

The product levy is a government-imposed penalty that becomes due if the prescribed recycling quotas for a calendar year are not met.

  • If a manufacturer is a proper member of a take-back system, the system assumes responsibility for meeting the quotas – the individual manufacturer pays the product levy only if they fulfill the requirements themselves or are not registered
  • Declaration via the BDO portal and payment directly to the Marschallamt by March 15

Who is considered a “manufacturer” under Poland’s packaging EPR regulations?

The EPR obligation applies to any company that places packaged products on the Polish market for the first time on a commercial basis – regardless of where the company is headquartered. Specifically, this applies to:

  • Fillers/packagers based in Poland – those who package or fill goods in Poland and sell them under their own brand name
  • Private-label owners – retailers who have products packaged by third parties and place them on the market in Poland under their own brand
  • Importers – those who commercially import packaged goods into Poland from abroad (EU or third countries)
  • Non-Polish EU companies engaged in distance selling – those who deliver packaged goods directly to Polish end customers via e-commerce (B2C) bear full EPR responsibility for product and shipping packaging – starting with the first shipment
  • Non-EU companies – for direct B2C shipments, the obligation lies with the foreign retailer; in traditional B2B supply chains, the Polish importer is legally considered the manufacturer
  • Marketplace operators – platforms such as Allegro and Amazon.pl bear subsidiary liability; they automatically validate BDO numbers and suspend accounts in cases of non-compliance with packaging regulations

Important – no quantity threshold: The BDO registration requirement applies in Poland starting with the first package placed on the Polish market. There is no exemption from the registration requirement for small quantities.

Practical example: An Austrian online store ships packaged cosmetic products directly to Polish consumers → is considered a manufacturer under the packaging EPR → must apply for a Polish NIP tax number → appoint an authorized representative in Poland → complete BDO registration with the Marshal’s Office in Warsaw (Masovia) → enter into a take-back system agreement → include the 9-digit BDO number on invoices → enter the BDO number in the Amazon.pl and Allegro backends

The 7 Most Important Steps for Packaging Compliance in Poland

Step 1: Appoint an Authorized Representative (for Foreign Companies)

Foreign online retailers not based in Poland that sell packaged goods directly to Polish consumers (B2C) must appoint an authorized representative based in Poland.

The authorized representative assumes joint and several financial and administrative responsibility for registration in the take-back system and for the annual report submitted via the BDO portal.

Requirements for the power of attorney documentation:

  • Written power of attorney in Polish (or bilingual Polish/English)
  • Proof of the foreign signatory’s authority to act on behalf of the company (e.g., an extract from the commercial register) must be attached
  • A Hague Apostille is not required as a standard for BDO registration
  • The foreign company must have a Polish NIP tax number so that the authorized representative can successfully complete the BDO registration process. The NIP must be applied for separately at the relevant tax office in Warsaw.

Step 2: Mandatory Registration in the BDO Registry

The BDO is Poland’s central, cross-product environmental and EPR registry – it combines packaging, WEEE, batteries, and other categories into a single system.

Registration platform: bdo.mos.gov.pl

Process:

  1. Fully digital application in Polish
  2. Required information: NIP, packaging materials (plastic, paper, glass, etc.), proof of a take-back system contract
  3. Upon approval by the Marshal, a unique 9-digit BDO number is assigned

BDO annual fee: Due by the end of February of each year

The BDO fee is a flat rate that applies to all registered categories – those who register packaging, WEEE, and batteries pay the same flat rate.

Step 3: Membership in a Take-Back System

Membership in a government-approved take-back system is mandatory. In Poland, there are several approved systems competing with one another.

Individual Self-Management:

  • Practically irrelevant for household packaging (B2C): The manufacturer would have to provide mathematical proof that it recovers exactly its own packaging waste from all Polish households.
  • Permitted in the pure B2B sector (e.g., transport pallets between industrial companies) through direct, documented contracts with commercial customers

Step 4: Collect packaging data and report annually

Content of the report: Exact weight figures (in kg) for all packaging placed on the market in Poland in the previous year, broken down by material type and intended use (B2C vs. B2B).

Deadlines:

  • Annual report: By March 15 of each year, submitted electronically via the BDO portal
  • Intra-year reports: Take-back systems require monthly or quarterly declarations in the system’s backend for billing purposes

Step 5: Calculate and Pay Fees

License fee to the take-back system: Calculated per metric ton/kilogram of packaging material placed on the market, strictly separated by material group.

Eco-modulation:

  • Benefits: Unpigmented monomaterials (e.g., clear PP or PE without barrier layers) and recyclable packaging receive fee discounts
  • Penalty surcharges: Multilayer plastics without a recycling pathway are subject to surcharges

Step 6: Deposit System – Active Since October 1, 2025

The Polish national deposit system has been in operation since October 1, 2025.

Covered packaging and deposit amounts:

  • Single-use PET bottles up to 3 liters: 0,50 PLN
  • Metal cans up to 1 liter: 0,50 PLN
  • Reusable glass bottles up to 1.5 liters: 1,00 PLN

Exceptions: Packaging for dairy products and small bottles below certain volumes are exempt.

Obligations for beverage manufacturers and importers:

  • Register packaging subject to the deposit with the relevant system operator
  • Affix the “Kaucja” logo and the deposit amount to the packaging (with a barcode)
  • Pay system fees to the operator

Step 7: Labeling, BDO Number on Documents & Product Delivery

1. Material Labeling:

  • Requirement to label materials with the Europe-wide harmonized identification codes

2. BDO Number on Business Documents:

  • The 9-digit BDO number must appear on all invoices, delivery notes, and commercial documents issued by the distributor

3. Product Levy:

The product levy is a government-imposed penalty that becomes due if the prescribed recycling quotas for a calendar year are not met.

  • If a manufacturer is a proper member of a take-back system, the system assumes responsibility for meeting the quotas – the individual manufacturer pays the product levy only if they fulfill the requirements themselves or are not registered
  • Declaration via the BDO portal and payment directly to the Marschallamt by March 15

Step-by-Step Checklist

(a) Companies based in Poland

1. Audit: Quantity and material inventory (separation of B2C and B2B due to different take-back and recycling obligations)

2. Contract: Sign a contract with a Polish recycling organization

3. BDO Registration: Obtain the 9-digit ID before the physical launch of sales

4. ERP System: Integrate the BDO number into invoices and receipts

5. Administrative Fee: Due annually by February 28

6. Reports: Submit data to your take-back system during the year (frequency depending on the contract)

7. Annual Report: Submit an electronic final report via the BDO portal by March 15 for the previous year

8. Deposit: If applicable, additional registration with the deposit system operator.

(b) Companies from other EU countries

1. Apply for a Polish NIP tax number for foreign companies

2. Appoint an authorized representative based in Poland; attach a power of attorney in Polish and an extract from the commercial register

3. The authorized representative enters into a take-back system agreement on behalf of the foreign merchant

4. Complete BDO registration through the authorized representative; obtain a 9-digit BDO number

5. Enter the BDO number in the seller account on Amazon.pl, Allegro, and other marketplaces

6. Ensure that the annual volume report is submitted by March 15 through the authorized representative

7. Do not forget to include shipping boxes and packing materials in the volume report

(c) Companies from third countries (outside the EU)

1. Check the distribution channel: Delivery to a Polish B2B trading partner → the partner, as the importer, assumes the manufacturer’s obligations; contractually provide all material data (weights by material type)

2. Direct shipment to Polish end customers without a Polish intermediary → all steps listed in (b) must be handled through a Polish authorized representative

Step-by-Step Checklist

(a) Companies based in Poland

1. Audit: Quantity and material inventory (separation of B2C and B2B due to different take-back and recycling obligations)

2. Contract: Sign a contract with a Polish recycling organization

3. BDO Registration: Obtain the 9-digit ID before the physical launch of sales

4. ERP System: Integrate the BDO number into invoices and receipts

5. Administrative Fee: Due annually by February 28

6. Reports: Submit data to your take-back system during the year (frequency depending on the contract)

7. Annual Report: Submit an electronic final report via the BDO portal by March 15 for the previous year

8. Deposit: If applicable, additional registration with the deposit system operator.

(b) Companies from other EU countries

1. Apply for a Polish NIP tax number for foreign companies

2. Appoint an authorized representative based in Poland; attach a power of attorney in Polish and an extract from the commercial register

3. The authorized representative enters into a take-back system agreement on behalf of the foreign merchant

4. Complete BDO registration through the authorized representative; obtain a 9-digit BDO number

5. Enter the BDO number in the seller account on Amazon.pl, Allegro, and other marketplaces

6. Ensure that the annual volume report is submitted by March 15 through the authorized representative

7. Do not forget to include shipping boxes and packing materials in the volume report

(c) Companies from third countries (outside the EU)

1. Check the distribution channel: Delivery to a Polish B2B trading partner → the partner, as the importer, assumes the manufacturer’s obligations; contractually provide all material data (weights by material type)

2. Direct shipment to Polish end customers without a Polish intermediary → all steps listed in (b) must be handled through a Polish authorized representative

Are you planning to sell your products in Poland?

We’ll help you ensure compliance with Poland’s EPR regulations for packaging so you can get started with legal certainty.

Are you planning to sell your products in Poland?

We’ll help you ensure compliance with Poland’s EPR regulations for packaging so you can get started with legal certainty.

Contact

We look forward to your message!

info@ecopv-eu.com

+49 6196 5835357

Frankfurter Str. 70-72
65760 Eschborn

Contact

We look forward to your message!

info@ecopv-eu.com

+49 6196 5835357

Frankfurter Str. 70-72
65760 Eschborn